As promised, the AAFP has prepared a summary of the 2019 final Medicare physician fee schedule(4 page PDF) to help family physicians digest the portions of the rule that will most affect their practices in the coming year and beyond.
The summary also points out important wins where AAFP guidance on key issues averted questionable CMS proposals that would not have benefitted physicians or their patients.
The final rule(s3.amazonaws.com) was filed for public inspection on Nov. 1 and is scheduled for publication in the Federal Register on Nov. 23.
The AAFP continues its in-depth review of the massive document and will provide, on behalf of members, further comment on certain sections as requested by CMS ahead of the Dec. 31 deadline.
For family physicians who need to get on with treating patients today, here is a rundown of topics covered in the summary.
Perhaps the most contentious item in the proposed 2019 fee schedule was the introduction of CMS' controversial blended payment rate for evaluation and management (E/M) visit levels two, three and four. Importantly, CMS delayed for two years, until Jan. 1, 2021, the implementation date for the collapse of those middle E/M code levels. Physicians likely remember that levels one and five were left untouched.
Two-year implementation delays were finalized in other areas, as well, with CMS vowing to consider further suggestions provided by stakeholders -- including the AAFP, the AMA and the CPT Editorial Panel -- in that expanded time period.
Importantly, the final rule omits two parts of the proposed rule that the AAFP objected to: add-on codes for primary care and a multiple-procedure payment reduction that would have reduced by half payment for office visits that occur on the same date as a procedure or other services.
The AAFP summary also includes details on
- the 2019 Medicare conversion factor of $36.0391, which is a tad higher than in 2018;
- site-neutral payment policies that advance efforts to align payment for independent practices with those of hospital-owned practices;
- separate payment for communication technology-based services such as virtual check-in, remote evaluation of recorded video or images, and new coding that describes chronic care remote physiologic monitoring;
- the addition of an individual's home as an acceptable origination site for telehealth services provided for treatment of a substance use disorder or co-occurring mental health disorder;
- the addition of two Healthcare Common Procedure Coding System "G" codes for telehealth services; and
• finalization of payment to rural health clinics and federally qualified health centers for communication technology-based services and remote evaluation services.
The AAFP summary also highlights updates finalized in the 2019 fee schedule for year three of the Quality Payment Program that relate specifically to small practices.
For instance, CMS expanded the low-volume threshold to include those who
- have allowed charges of $90,000 or less for covered professional services,
- provide covered services to 200 or fewer part B-enrolled patients, or
- provide 200 or fewer covered services to part B-enrolled patients.
Another element of the fee schedule supported by the AAFP and finalized by CMS gives eligible clinicians who meet or exceed one or two elements in the low-volume threshold the choice to participate in the Merit-based Incentive Payment System.
Related AAFP News Coverage
In the Trenches blog: AAFP Offers CMS Five Major Changes to Fee Schedule